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Corrective Actions Taken <br />0 <br />14 <br />Corrective <br />S H <br />Below is a brief summary of Fleetwash's corrective actions in response to the violations noted <br />during the hazardous waste inspection that took place on October 21, 2010, the report for which <br />Fleetwash received on November 3, 2010. The sections following this summary contain copies <br />of all bills of lading and manifests mentioned herein. Where necessary, photographs showing <br />proof of correction have been taken and those are attached as well. <br />Line Item 7: Failed to determine if a waste is a hazardous waste. <br />Response / Follow -Up: Solids filtered from the waste water generated from truck wash <br />operations have been sample and tested. In a telephone conversation on November 22, 2010 <br />between Fleetwash manager Ralph Colonna and San Joaquin County Environmental Health <br />Department Inspector Muniappa Naidu, Ralph was informed that the county's lab results show <br />the solids to be non -hazardous waste. Fleetwash sent the split sample out for testing as well, and <br />is awaiting the results. <br />In the course of his conversation with Mr. Naidu, Ralph Colonna was informed that while the <br />solids are non -hazardous waste, they must be disposed of at a Class H Landfill. Daniel Carlton, <br />assistant regional manager for Fleetwash, has consulted with Robert McClellan of the San <br />Joaquin County Environmental Health Department regarding proper handling of this waste. <br />As a result of these discussions, Fleetwash will implement the following disposal practice for <br />this waste: <br />1) Fleetwash will obtain a letter of acceptance from the Forward Landfill (located at 9999 S. <br />Austin Road in Manteca, California) for the disposal of solids from the truck wash waste <br />water. Forward Landfill is a Class II Landfill operated by Republic Services. As required, <br />Fleetwash will provide Republic Services with a waste profile prior to Republic Services <br />issuing acceptance of the waste. <br />2) As processed solids are removed from the waste treatment system, they will be placed in <br />a 55 gallon drum. <br />3) The drum will be sealed except to add or remove solids, It will be properly labeled and <br />transported to Forward Landfill within 6 months of the accumulation start date. <br />4) Fleetwash will maintain receipts the landfill for all loads removed from the facility. <br />Fleetwash manager Ralph Colonna will be responsible for the maintenance of these records. <br />Ralph Colonna will also be responsible for ensuring that any aerosol cans disposed of at the <br />facility are completely empty prior to being placed in a trash receptacle. In the event he is unable <br />